ML20115J654

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Rev 1 to Application for Amend to License DPR-16,consisting of Tech Spec Change Request 100,deleting Table 3.5.1, Revising Section 3.5.A.8 & Bases & Section 4.5.Q & Bases Re Snubber Insp Per Generic Ltr 84-13.Fee Paid
ML20115J654
Person / Time
Site: Oyster Creek
Issue date: 04/15/1985
From: Fiedler P
GENERAL PUBLIC UTILITIES CORP.
To:
Office of Nuclear Reactor Regulation
Shared Package
ML20115J656 List:
References
GL-84-13, NUDOCS 8504240059
Download: ML20115J654 (8)


Text

r GPU Nuclear Corporation NUCIM7 100 lnterpace Parkway Parsippany. New Jersey 07054-1149 (201)263-6500 TELEX 136-482 Wnter's Direct Dial Number:

April 15, 1985 Director, Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Sir:

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Revision No. 1 to Technical Specification Change Request No. 100 On December 10, 1982, in accordance with 10CFR50.59 and 10CFR50.90, GPU Nuclear Corporation, operator of the Oyster Creek Nuclear Generating Station, Provisional Operating License DPR-16, submitted Technical Specification Change Request No. 100.

Technical Specification Change Request No. 100 involved changes to Section 3.5.A.8 and basss, Section 4.5.Q and bases,'Section,6.10.2 and Table 3.5.1.

The intent of these changes was to incorporate Revision 1 offthe Inservice Inspection Surveillance Requirements for snubbers under the Standard Technical Specifications which were transmitted by the D.G. Eisenhut letter of March 23, 1981, and to revise Table 3.5.1 to add the mechanical snubbers.

Subsequent to the submittal of Technical Specification Change Request No. 100, on May 3, 1984, the Commission issued Generic Letter 84-13 which stated that snubber listings within the technical specifications are not necessary, provided the snubber technical specification be modified to specify which snubbers are required to be operable. Generic Letter 84-13 was later made applicable to all SEP plants, which includes the Oyster Creek Nuclear Generating Station.

GPU Nuclear Corporation has reviewed Generic Letter 84-13, and hereby submits Revision No. 1 to Technical Specification Change Request No. 100 in response to that letter. This revision changes our original submittal of December 10, 1982 to delete Table 3.5.1 from the Oyster Creek Nuclear Generating Station Technical Specifications; and to revise Section 3.5.A.8 and bases, Section 4.5.Q and bases, and Section 6.10.2 of the Technical Specifications; and to delete references to Table 3.5.1.

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ceu nuciear corporation is a subsidiary of ceneral Pubhc Utihties Corporation y

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.. In view of the time lapsed since our submittal of December 10, 1982, both the proposed changes noted in Technical Specification Change Request No. 100 and the proposed changes in response to Generic Letter 84-13 are included in this Revision No. 1.

This Revision No. 1 to Technical Specificaton Change Request No. 100 has been reviewed in accordance with Section 6.5 of the Oyster Creek Nuclear Generating Station Technical Specifications.

Pursuant to 10CFR50.91(b)(1), a copy of Revision No. I to Technical Specification Change Request No. 100 has been sent to the State of New Jersey Department of Environmental Protection.

In accordance with 10CFR170.21, Revision of License Fee Schedule, effective on June 18, 1984, we have enclosed a check for $150.00 pursuant to the new schedule of Facility Fees. Also, a check for $4,000.00 dated July 11, 1983 has already been provided for Technical Specification Change Request No. 100.

Very truly yours,

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Vice President and Director Oyster Creek 1419f cc: Administrator Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.

19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, N. J.

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GPU NUCLEAR CORPORATION OYSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE NO. DPR Revision No. 1 to Technical Specification Change Request No. 100 Docket No. 50-219 Applicant submits, by this Revision No. 1 to Technical Specification Change Request No. 100 to the Oyster Creek Nuclear Generating Station Technical Specifications, a change to Specification 3.5.A.8 and bases, Specification 4.5.Q and bases, Specification 6.10.2, and Table 3.5.1.

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By:

P. 6. Titiffler Vice President & Director Oyster Creek Swornandsubscribedtobeforemethis/

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DIANA A. 3fALTh A Noran Pu%c of New Jerse -

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a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF

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DOCKET NO. 50-219 GPU NUCLEAR CORPORATION

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CERTIFICATION OF SERVICE This is to certify that a copy of Revision No. I to Technical Specification Change Request No. 100 for the Oyster Creek Nuclear Generating Station Technical Specifications, filed with the U.S. Nuclear Regulatory Commission on Aor'l 15

, 1985, has this 15th day of April, 1985 been served on the Fayor of Lacey Township, Ocean County, New Jersey by deposit in the United States mail addressed as follows:

Mayor of Lacey Township 818 W. Lacey Road Forked River, New Jersey 08731 9

j By:

-e P. B. FiedTer

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Vice President & Director Oyster Creek

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o GPU Nuclear Corporation NUCIM7 100 Interpace Parkway Parsippany. New Jersey 07054-1149 (201)263-6500 TELEX 136-482 Writer's Direct Dial Number-April 15,1985 Mayor of Lacey Township 818 W. Lacey Road Forked River, New Jersey 08731

Dear Mayor:

Enclosed herewith is a copy of Revision No. 1 to Technical Specification Change Request No. 100 for the Oyster Creek Nuclear Generating Station Technical Specifications.

These documents were filed with the U.S. Nuclear Regulatory Commission on April 15 1985.

Very truly yours,

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.-a P. B.

dier Vice President & Director Oyster Creek 1419f GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation

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OYSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE DPR-16 DOCKET N0. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST N0. 100 AND REVISION N0. 1 TO TECHNICAL SPECIFICATION CHANGE REQUEST NO. 100 Applicant hereby requests the Commission to amend Appendix A of the above captioned license to incorporate the changes proposed in our Technical Specification Change Request No. 100 of 4

December 10, 1982 as modified by this Revision No. I to said request. Pursuant to 10CFR50.91, an analysis concerning signi-ficant hazards considerations is provided below:

1.

Sections to be changed:

a.

Section 3.5.A.8 and bases b.

Section 4.5.0 and bases c.

Section 6.10.2 d.

Table 3.5.1 2.

Extent of changes:

a.

Section 3.5.A.8, Shock Suppressors (Snubbers), and Bases Revise wording (Technical Specification Change to conform to NRC Standard Technical

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Specification Request No. 100) and delete reference to Table 3.5.1 (Revision No. 1 to Technical Specification Change Request No. 100).

b.

Section 4.5.Q, Shock Suppressors (Snubbers), and Bases Revise to define the Visual Inspection Acceptance criteria; establish guidelines to be used in choosing sample snubbers for functional testing;

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define Functional Test acceptance criteria for Hydraulic and Mechanical Snubbers; and add the requirement for Snubbers Service Life Monitoring (Technical Specification Change Request No. 100).

Delete reference to Table 3.5.1 (Revision No. 1 to Technical Specification Change Request No. 100).

c.

Section 6.10.2, Record Retention Add the requirement to keep records of the snubbers' service lives (Technical Specification Change Request No. 100).

Delete reference to Table 3.5.1 (Revision No. 1 to Technical Specification Change Request No. 100).

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Delete table (Revision No. 1 to Technical Specification Change Request No. 100).

3.

Changes requested:

The requested changes are shown on the attached revised Technical Specification pages 3.5-3, 4.5-6a, 4.5-6a-1, 4.5-6a-2, 4.5-6a-3 and 6.23. Revised Bases pages 3.5-5, 3.5-6 and 4.5-9b are also attached.

Revised Table 3.5.1, page 3.5-8, is shown as deleted, and page 3.5-13a which contains Table 3.5.2, has been renumbered as 3.5-9 and page 3.5-14 has been renumbered as 3.5-10.

4.

Discussion The discussion included with Technical Specification Change Request No.

100 is still applicable, and is repeated here for completeness:

Technical Specification 3.5.A.8 cites the requirements for Shock Suppressors (Snubbers). Technical Specification 4.5.Q cites the requirements for the surveillance of the snubbers.

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I The purpose of this Technical Specification Change Request is to revise j

the requirements for the snubbers to include the Mechanical Snubbers and to incorporate the Inservice Surveillance Requirements which were transmitted via the D. G. Eisenhut letter of March 23, 1981.

This requested change to the Technical Specifications differs from the Standard Technical Specifications in the following areas:

1.

With respect to the performance of an engineering evaluation on the components which are suppported by the snubber found to 3

be inoperable; the licensee is not prepared to implement this type of change to the snubber surveillance program. The licensee contends that this requirement involves extensive computer modeling of piping supports and configurations which currently do not exist at this facility. Also, the requirement to perform an engineering evaluation is judged unreasonable since an inoperable snubber will be replaced or restored to being operable.

2.

With respect to Visual Inspection Acceptance Criteria for snubbers, which appear inoperable, the two (2) criteria for i

determining their operability for the purpose of establishing the next visual inspection interval were changed from an "ANO" to an "0R" requirement. The licensee contends that this change affords more flexibility in determining that questionable snubbers are indeed. operable. The licensee considers it unlikely that a snubber which appears inoperable as per the acceptance criteria would be able to be functionally tested in the as-found condition. Therefore, to include this criteria as an "AND" requirement is believed to 4

be too restrictive and may adversely affect inspection intervals and plant-operations.

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3.

With respect to the functional testing equipment that if a snubber fails to lockup or move, the cause will be evaluated and if caused by manufacturer or design deficiency, that all snubbers of the same design subject to the same defect shall be functionally tested; this requirement was deleted. Since there are only two (2) types of snubbers at the facility, this requirement could easily result in the functional testing of all of the snubbers instead of the representative sample requirement. For this reason, the above requirement was deleted from the specification.

The purpose of Revision No. 1 to Technical Specification Change Request No.

100 is to delete the snubber listings for the Technical Specification in response to Generic Letter 84-13.

5.

Determination We have determined that the proposed changes in Technical Specification Change Request No. 100 involve a change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications. Furthermore, the proposed changes in Revision No. 1 to Technical Specification Change Request No. 100 involve purely administrative changes to the technical specifications.

Based on the above, operation of the Oyster Creek Nuclear Generating Station in accordance with Technical Specification Change Request No. 100 and Revision No. I thereto would not:

1.

Involve a significant increase in the probability or consequence of an accident previously evaluated; or 2.

Create the possibility of a new or different kind of accident from any previously evaluated; or 3.

Involve a significant reduction in a margin of safety.

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